1. Introduction
This Privacy Policy explains how we collect, use, process, and protect your personal data. By using our platform, you agree to this policy.
2. Data We Collect
- Personal Information: Full names, emails, phone numbers, gender, qualifications, skills, CVs, and locations.
- Payment Details: Information necessary for processing registration fees.
- Other Information: Data that helps us provide and improve our services, including your goals and preferences.
- Cookies: Cookies, pixels, and similar technologies are used for site functionality, analytics, and advertising.. For more details, see our Cookie Policy.
- Sensitive Data: Unless you expressly agree, we do not process your sensitive data.
3. How We Use Your Data
- For Students: To facilitate enrollment, communicate about courses, and process payments.
- For Tutors: To review applications, conduct the selection process, and manage tutor accounts.
- Improvement: To analyze site usage and improve our services.
- Analytics and Development: To assess platform performance and develop new features.
- Identifying Influencers: To identify potential influencers for collaborations.
- Language Assessment: To assess your level of language proficiency, including processing your name, email address, and assessment results, either before or after you register on our platform.
- Analysis of Speech Activity: When giving or taking lessons, we may analyze microphone activity and measure sound volume to provide feedback on your speaking activity. We do not record your voice or conversations for this purpose. Users in the European Economic Area (EEA) or Switzerland will have the option to turn this feature off.
- Information Processed by AI-Powered Tools: To enhance your experience, we use AI-powered tools provided by trusted third-party vendors for tasks such as generating personalized learning recommendations, lesson plans, grammar explanations, and language proficiency assessments. These tools may process your data in accordance with strict privacy and security standards.
4. Legal Basis for Processing
We process your data based on the following legal grounds:
- Consent: For optional activities like marketing communications.
- Contract Performance: To fulfill our obligations to you (e.g., enrollment, payments).
- Legitimate Interest: To improve our services and ensure platform security.
- Legal Obligations: To comply with applicable laws and regulations
5. Data Sharing
We may share data with third parties, such as payment processors, to fulfill our services. Specifically, we may share data with:
- Payment Processors: To process transactions securely and efficiently.
- Service Providers: Third parties that assist us in providing our services, such as cloud storage providers (e.g., AWS, Google Cloud) and analytics companies (e.g., Google Analytics). These providers are contractually obligated to protect your data and comply with applicable privacy laws.
- Legal Authorities: When required by law to comply with legal obligations, subpoenas, or court orders. We will verify the legitimacy of any such request before disclosing your data.
6. International Data Transfers
If your data is transferred outside your region (e.g., from the EU to the MEA region), we ensure it is protected through:
- Standard contractual clauses.
- Other legally recognized mechanisms for international data transfers.
7. Independent Contractors
We work with independent contractors who assist us in providing our services. These contractors undergo rigorous vetting and are bound by strict confidentiality agreements to ensure your data is protected. Specifically, we may engage such contractors to support us with:
- Data analytics and software development
- Customer support
- Promotion and marketing
- User research
- Financial and legal matters
These contractors may have access to your personal data strictly on a need-to-know basis and will be subject to strict privacy and security obligations to ensure your data is protected.
8. Sale of Personal Data
We do not sell your personal data to third parties for monetary or other valuable consideration. We also do not share your data for advertising or partnership purposes without your explicit consent. If this policy changes in the future, we will provide users with clear notice and obtain your explicit consent, where required, before proceeding with any such sale.
9. Disclosure of Personal Information to Law Enforcement Officials
We may disclose your personal information to law enforcement, government authorities, or other officials when:
- Required to comply with a legal obligation, subpoena, or court order.
- Necessary to protect the safety, rights, or property of our platform, users, or the public.
- In connection with investigations into potential illegal activities, fraud, or security breaches.
We will take reasonable steps to verify the legitimacy of any such request and ensure that the disclosure complies with applicable laws and regulations.
10. Cookies and Tracking
Cookies are used to enhance your browsing experience. You can manage cookie preferences through your browser settings. For more details, refer to our Cookie Policy
11. Data Storage and Security
Your data is stored securely and protected from unauthorized access using industry-standard security measures, including encryption, access controls, and secure server environments. We will take reasonable steps to verify the legitimacy of any such request and ensure that the disclosure complies with applicable laws and regulations. We retain your data only as long as necessary to fulfill the purposes outlined in this policy or comply with legal obligations. When no longer needed, we securely delete or anonymize it.
12. How Long Personal Data Will Be Processed and Stored
- General Storage Duration: Personal data is stored for the duration of your use of our services. If your account is closed, data will be deleted or anonymized within 30 days, unless required by law.
- Legal Retention Obligations: Data such as payment records may be retained longer for compliance with financial, tax, or legal regulations.
- Inactive Accounts: Accounts inactive for 12 months will be flagged, and personal data may be anonymized or deleted unless legally required otherwise.
- Data Processed for Analytics: Anonymized or aggregated data for analytics and improvement purposes may be retained indefinitely.
- Criteria for Retention: The duration of data retention will depend on factors such as the nature of the data, the purposes for which it was collected, and any applicable legal obligations.
13. Safety and Compliance with Law
We ensure the safety of your personal data and comply with applicable laws, including GDPR for users in Europe.
14. Children’s Privacy
Our platform is not intended for children under 18 years old. To ensure compliance with COPPA (Children’s Online Privacy Protection Act) or other relevant regulations, we verify the age of users by requiring a date of birth upon registration. Age verification methods include checking user input against legal age. We do not knowingly collect personal data from children without parental consent. If such data is identified, it will be promptly deleted. Parents or guardians who believe their child’s data has been collected can contact us at contact@myluftschloss.com.
- Users under 18 must provide written consent from a parent or guardian, along with a government-issued ID for verification. Luftschloss reserves the right to request additional documentation to verify age.
15. User Rights
You have the following rights regarding your data:
- Access: Request access to your data.
- Correction: Request corrections to inaccurate or incomplete data.
- Deletion: Request deletion of your data, subject to legal obligations.
- Right to Erasure: You can request the erasure of personal data unless required by law to retain it.
To exercise these rights, contact us at contact@myluftschloss.com. We will respond within 30 days of your request. You may be required to verify your identity before we process your request.
16. Time for Reply and Reaction
We aim to respond promptly to your inquiries or concerns:
- General Inquiries: Respond within 7 business days.
- Requests Related to Your Rights: Provide an initial response within 30 days. In exceptional cases, an additional 30 days may be required, and you will be informed of the extension.
17. Communications and Newsletters
We may send you newsletters, updates, or promotional content. You can opt-out of these communications at any time by following the unsubscribe instructions in the email.
18. Behavioral and Social Media Marketing
We may use your data to personalize marketing efforts on social media and other platforms. You will be notified before engaging in such activities, which comply with privacy laws. We do not share your data with social media platforms without your consent.
19. Additional Data Collection
We may collect additional data to facilitate language assessments, video lessons, sales calls, and to organize events or webinars. This data will only be used for the specified purposes and will not be shared without your consent.
20. Changes to the Privacy Policy
We may revise this Privacy Policy periodically. When we make significant changes, we will:
- Notify the users through the platform and via email and update the revision date at the top of this policy.
- Provide clear details on what changes have been made and how they may affect you.
It is your responsibility to periodically review this Privacy Policy to stay informed about any updates.
21. Data Breach Notification
In the event of a data breach that affects your personal data, we will notify you within 72 hours of becoming aware of the breach. Notifications will be sent via email and will include details about the nature of the breach, the data affected, and steps you can take to protect yourself.
22. Governing Law
These Terms and Conditions are governed by the laws of the regions where our branches or offices are located. Any disputes related to these Terms will be resolved exclusively by the courts in these regions, unless local law requires otherwise. Users from other regions should note that their data will be processed in accordance with applicable local laws.
23. Conclusion
By accessing or using the Luftschloss platform, you acknowledge that you have read, understood, and agreed to abide by these Privacy Policy. If you do not agree to these Terms, please do not use our services.
For any questions, concerns, or feedback regarding these Terms and Conditions, please contact us at contact@myluftschloss.com.
Thank you for choosing Luftschloss!
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